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Should I take part in the Quality Payment Program and MIPS?

3/17/2023

The Centers for Medicare and Medicaid Services provides the following information:

You may have heard that the Centers for Medicare & Medicaid Services (CMS) is reviewing claims and advising practices on which doctors should participate in the Merit-based Incentive Payment System (MIPS). MIPS is an essential component of the new Quality Payment Program.

The Quality Payment Program aims to improve Medicare by putting patients first and paying clinicians based on their success. It replaces the Sustainable Growth Rate formula, which threatened Medicare clinicians with payment cutbacks for 13 years. This initiative combines and streamlines many existing Medicare quality programs. It also provides novel methods to improve care delivery by supporting and rewarding clinicians who:
Find new methods to engage patients, families, and caregivers. 
Improve care coordination and community health management. 

During the first year of the Quality Payment Program, CMS is dedicated to working hard with clinicians to make the reporting and participation process simpler. CMS's goal is to further reduce burdensome requirements so that clinicians can provide the best possible care to patients. 

Here are eight methods to find out if you're eligible for the Quality Payment Program: 
1.To verify your status, go to qpp.cms.gov, click on the MIPS Participation Look-up Tool, and enter your National Provider Identifier (NPI). In addition, you may have recently received a notice from your Medicare Administrative Contractor (MAC) indicating whether you are eligible for MIPS. Your practice should have received a letter detailing the MIPS participation status of each clinician linked with the practice's Taxpayer Identification Number (TIN).

2.You are:
  • Doctor of medicine, doctor of osteopathy (including osteopathic practitioners), doctor of dental surgery, doctor of dental medicine, doctor of podiatric medicine, doctor of optometry or a chiropractor. 
  • Physician assistant
  • Licensed practical nurse
  • Clinical nurse specialist
  • Registered nurse anesthetist
  • A group comprised of such doctors
3.You are a MIPS-eligible clinician who bills $30,000 or more in Medicare Part B allowed charges per year AND cares for more than 100 Part B-enrolled Medicare patients. If you completed both, you are eligible for MIPS for the 2017 transfer year. In other terms, you have exceeded the "low-volume threshold." CMS calculated billing and patient traffic by analyzing claims data from September 1, 2015 to August 31, 2016. CMS will use claims data from September 1, 2016 to August 31, 2017 to identify new low-volume clinicians.
NOTE: The CMS has increased the low-volume provider eligibility requirement for 2018 to $90,000 or 200 patients.

4.You are not new to Medicare in 2017. If you started in 2017, you are not eligible for MIPS. 

5.Your practice indicates that the group in which you are a member is taking part. Every practice should inform its doctors about their MIPS status. If you operate under more than one TIN, you will be notified of your status for each TIN separately. Your status may vary between TINs. You could, for example, be a part of two practices with distinct TINs. Your Medicare billing and patient count may exceed the low-volume threshold in one business but not in the other.

6.Your office has decided to take part in MIPS as a group. If your group decides to join, you will be evaluated and scored as a group.

7.You did not engage in Advanced Alternative Payment Models (APMs) sufficiently to become a Qualifying APM Participant (QP).If you did, you’re exempt from participating in MIPS.  If you are in an Advanced APM and become a Partial QP, you have the option of reporting on MIPS measures and actions, being scored using the APM scoring standard, and receiving a MIPS payment adjustment. Partial QPs can opt out of MIPS, but they must still satisfy the participation requirements of their APMs.

8.You want to take part. Even if you are not required to engage in the MIPS program, you may choose to do so. You will not be liable to MIPS payment adjustments if you do so.

The Quality Payment Program provides free tools to assist. 
Visit the CMS's main website at qpp.cms.gov. 
Send an email to qpp@cms.hhs.gov or call 1-866-288-8292 (toll-free) or   1-877-715-6222 (TTY)

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